PFS proposed rule comment ltr final 8 24 10 final x

August 24, 2010 Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: CMS-1503-P, Medicare Program; Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2011; Proposed Rule; (Vol. 75, No. 86), July 13, 2010. Dear Dr. Berwick: On behalf of our more than 5,000 member hospitals, health systems and other health care organizations, and our 40,000 individual members, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule with changes to the physician fee schedule (PFS) and other Medicare Part B payment policies for calendar year (CY) 2011, including the implementation of a number of provisions in the Patient Protection and Affordable Care Act of 2010 (ACA). Physicians are critical partners with America’s hospitals, which employ more than 188,000 physicians (including interns and residents), or approximately 20 percent of all doctors in the U.S. Hospitals are paid for certain outpatients services, such as physical and occupational therapy, under the Medicare PFS. In addition, the proposed rule discusses payment changes under the ambulance fee schedule (AFS) and clinical laboratory fee schedule (CLFS), as well as payments for Part B drugs – all of which impact our members. This letter addresses ...